Material Loss Review of Signature Bank of New York, EVAL-24-02 (Part 2 of 2)

Bitcoin Research — Law, Regulation, Markets & Origins (2026)

Banking

2

2023-10

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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.

Act
                               Amend Client Anticipated Account Activity Reports form to capture all permitted
   1        SR-2020 BSA #02
                               client products and activities
                               Ensure decisions for clearing or escalating automated transaction monitoring
    2       SR 2020 BSA #03
                               system alerts reflect analyses of actual account activity
    3       SR 2020 BSA #01    Ensure higher-risk customer account reviews document underlying activity
 Commercial & Industrial Loan Portfolio
    1       SR-2021 C&I #01    Increase reporting frequency of credit underwriting exceptions
 Commercial Real Estate
                               Improve documentation of real estate evaluation assumptions for collateral
    1      SR-2021 CECL #01
                               dependent commercial real estate loans
 Credit Risk Management
    1       SR-2019 CRM #02    Develop procedures to review borrower risk
    2       SR-2019 CRM #08    Formalize loan pricing methodologies
    3       SR-2021 CRM #01    Develop action plan to improve risk rating framework
                               Adhere to policy for real estate appraisals on distressed commercial real estate
    4       SR-2021 CRM #02
                               loans
 Enterprise Risk Management
    1      SR-2018 ERM #04a Ensure an effective issue tracking system is in place
 Liquidity
    1       SR-2019 LIQ #01a   Better support assumptions for deposit run-off in stress testing scenarios
    2       SR-2019 LIQ #01c   Consider the impact of high rate deposits in the stress testing scenario
    3       SR-2019 LIQ #02a   Document support for the deposits quantitative risk-rating framework
                               Consider depositors’ sensitivity to bank conditions as part of the deposit rating
    4       SR-2019 LIQ #02b
                               framework
    5       SR-2019 LIQ #03a   Establish metrics to ensure liquidity level is sufficient at time intervals
    6       SR-2019 LIQ #03b   Conduct sensitivity testing of key assumptions in the liquidity stress test
    7       SR-2019 LIQ #03c   Improve liquidity stress testing model documentation
    8       SR-2019 LIQ #03d   Ensure adequate validation of stress testing includes effective challenge
    9       SR-2019 LIQ #04d   Consider potential impact on capital from actions taken to raise liquidity
   10        SR-2019 LIQ #05   Improve system of effective challenge for stress modeling methodology
   11        SR-2019 LIQ #06   Improve internal controls relating to liquidity risk management
 Model Risk Management (MRM)
    1      SR-2021 MRM #01     Expand MRM policy and establish standards for use of models with exceptions
    2      SR-2021 MRM #02     Expand policy with standards and procedures for resolving outstanding findings
    3      SR-2021 MRM #03a Establish documentation standards for third-party vendor models
    4      SR-2021 MRM #03b Establish model document repository and indexing system
    5      SR-2021 MRM #04a Expand scope of validations to include challenge to external data applicability
    6      SR-2021 MRM #04b Ensure model validation assesses forecast accuracy of model outputs
                               Ensure variable selection process and assumptions are documented,
    7      SR-2021 MRM #04c
                               substantiated
    8      SR-2021 MRM #04d Document critical assumptions and limitations associated with model data
                               Establish data governance program and data analysis to measure quality and
    9      SR-2021 MRM #04e
                               accuracy of inputs
                               Expand ongoing performance monitoring activities to include performance
   10      SR-2021 MRM #04f
                               assessments quarterly

                                                        45
                                                                                            Material Loss Review
                                                                                      Signature Bank of New York

 Count           SR No.                                          Brief Description
                                 Assess and measure impact of excluding a data segment by third-party model
   11      SR-2021 MRM #04g
                                 developer
                                 Perform sensitivity analysis as part of ongoing performance monitoring activities
   12      SR-2021 MRM #04h
                                 on critical model parameters
 Sensitivity to Market Risk
   1       SR-2018 SMR #01b      Report all policy exceptions to the Board or Board committee
   2       SR-2019 SMR #09a      Establish limits for flattened and steepened yield curve shift scenarios
   3       SR-2019 SMR #09b      Define acceptable variance limits in policy for all major assumptions
                                 Perform net income simulations in accordance with internal rate of return policy
    4      SR-2019 SMR #09c
                                 parameters
 Strategic Planning
            SR-2019 Strategic
    1                            Ensure the IAD evaluates the strategic planning process
              Planning #06
 Corporate Governance
                                 Incorporate standards, expectations for new or modified products following
    1         SR-2022 #01
                                 project approval track
                                 Ensure key risk metrics and limits are consistent with Board’s risk appetite, and
    2         SR-2022 #02
                                 monitored
                                 Review, update, approve Operational Risk Management Committee charter and
    3         SR-2022 #03
                                 policies
    4         SR-2022 #04        Ensure an effective Risk Control Self-Assessment framework is in place
 Information Technology
                                   Develop a comprehensive IT/IS Risk Assessment to include all of the business
    1        SR-2019 IT #01
                                   applications, hardware, and operating systems
                                   Ensure the IT Asset Inventory includes sufficient and accurate details on
     2        SR-2019 IT #02
                                   hardware and software
                                   Strengthen the Business Continuity Management program commensurate to the
     3        SR-2021 IT #01
                                   size, capacity, and risk profile of the bank
                                   Expand the project management policy to include defining projects based on
     4       SR-2021 IT #02b
                                   size and complexity
     5          SR-2022 #01        Improve management’s process for managing end of life systems
                                   Determine whether the common vulnerability scoring system should be updated
     6          SR-2022 #02
                                   to the latest version
                                   Ensure the Center for Internet Security standards are implemented for all
     7          SR-2022 #03
                                   operating systems and network devices
     8          SR-2022 #04        Expand management’s current Succession Plan
                                   Expand and increase project management reporting cadence to the Board or a
     9          SR-2022 #05
                                   Board-level committee
a
  This SR was included in the 2021 Report of Examination (ROE) and was elevated to an MRBA in 2022.
b
  This SR was included in the 2021 ROE, but was closed during 2022.

Matters Requiring Board Attention (MRBAs)
 Count        MRBA No.                                                  Description
 Liquidity
   1       MRBA-2019 LIQ #01     Ensure adequate liquidity contingency planning is in place
 Corporate Governance
                                  Implement an effective Issues and Event Management process and remediate outstanding
   1        MRBA-2022 #01a
                                  findings in a timely manner
                                  Ensure organizational structure, decision making at all levels are appropriate and
     2      MRBA-2022 #02
                                  consistent with emerging risks associated with strategic initiatives
a
  This MRBA was included in the 2021 ROE as an SR and was elevated to an MRBA in 2022.

                                                       46
            Part II
          ********

FDIC Comments and OIG Evaluation
                    FDIC Comments and OIG Evaluation

On October 16, 2023, the FDIC Director of RMS provided a written response to a draft of this report.
The response is presented in its entirety beginning on page II-2. In its response, the FDIC agreed
with the findings and concurred with all six recommendations in the report. The FDIC’s proposed
corrective actions and its actions taken to date were sufficient to address the intent of the
recommendations. The FDIC plans to complete all corrective actions for the recommendations by
March 31, 2024. Therefore, we consider all six recommendations to be resolved.

All recommendations in this report will remain open until we confirm that corrective actions have
been completed and the actions are responsive. A summary of the FDIC’s corrective actions begins
on page II-7.

October 2023   EVAL-24-02                           II-1
                    FDIC Comments

October 2023   EVAL-24-02           II-2
                    FDIC Comments

October 2023   EVAL-24-02           II-3
                    FDIC Comments

October 2023   EVAL-24-02           II-4
                     FDIC Comments

October 2023   EVAL-24-02            II-5
                    FDIC Comments

October 2023   EVAL-24-02           II-6
                       Summary of the FDIC’s Corrective Actions

 This table presents management’s response to the recommendations in the report and the
 status of the recommendations as of the date of report issuance.

   Rec.    Corrective Action: Taken or                 Expected        Monetary   Resolved:a   Open or
    No.              Planned                         Completion Date   Benefits   Yes or No    Closedb
    1     The FDIC issued instructions to             March 31, 2024      $0        Yes         Open
          examiners on August 29, 2023, via a
          regional director memorandum (RD
          Memo). Among other things, this RD
          Memo instructs examiners to perform
          enhanced follow-up and a progressive
          supervisory response for institutions
          that fail to address supervisory
          recommendations in a timely manner.

          The FDIC trained examiners on the
          new instructions on September 13,
          2023 and provided examiners an
          opportunity to comment on the
          instructions. FDIC officials will review
          the comments to determine whether
          adjustments or clarifications to the
          instructions are warranted. The FDIC
          is also preparing examples of
          escalation of supervisory
          recommendations, including MRBA,
          in order to deliver additional training
          to examiners by March 31, 2024.
    2     The FDIC issued an RD Memo on               March 31, 2024      $0        Yes         Open
          August 30, 2023 to examiners that,
          among other things, requires large
          bank examination teams to document
          their assessment of all component
          and composite ratings in quarterly
          ongoing monitoring reports.

          The FDIC trained examiners on these
          new instructions on October 4, 2023
          and examiners were provided the
          opportunity to comment on the
          instructions. The FDIC will review the
          comments to determine whether
          adjustments or clarifications to the
          instructions are warranted. The FDIC
          will also update the Risk Management
          Manual of Examination Policies by
          March 31, 2024 to emphasize to
          examiners the significance of prompt
          communication of risk and
          supervisory results to bank
          management.

October 2023    EVAL-24-02                               II-7
       3     The FDIC will conduct an evaluation          March 31, 2024         $0            Yes             Open
             of existing examination guidance to
             determine whether updates are
             warranted. The evaluation will be
             documented through a memorandum
             from FDIC staff to the Director, RMS.
             The memorandum will also address
             recommendations for pursuing
             updates if warranted.
       4     The Director, RMS, evaluated current        November 30, 2023       $0            Yes             Open
             practices and recommended changes
             to the FDIC’s strategies for attracting
             and retaining staff, including staff that
             examine large, complex financial
             institutions. The draft strategies were
             delivered to the FDIC Chairman on
             September 29, 2023. The Director,
             RMS, is also studying and will make
             recommendations related to the
             allocation of examiner staffing within
             the FDIC. Recommendations will be
             coordinated with the Director, Division
             of Administration; the General
             Counsel; and the Director, Division of
             Complex Institution Supervision and
             Resolution and documented through
             a memorandum to the FDIC
             Chairman.
       5     The FDIC will develop and implement          March 31, 2024         $0            Yes             Open
             target metrics for the items described
             in the recommendation and will
             develop a process for monitoring
             variances with the metrics. Examiner
             instructions regarding the target
             metrics and monitoring processes will
             be communicated via an RD Memo.
       6 RMS conducted an evaluation and                 December 31, 2023       $0            Yes             Open
         identified two sections of the Manual
         to update. RMS is updating the
         Liquidity section of the Manual to
         expand the discussion of the volatility
         of uninsured deposits and the
         importance of contingency funding
         plan considerations. This action will
         be completed by December 31, 2023.
         RMS is also updating the Report of
         Examination Instructions relative to
         the evaluation of concentrations of
         uninsured deposits. This action will
         be completed by October 31, 2023.
 a
   Recommendations are resolved when —

       1.   Management concurs with the recommendation, and the OIG agrees the planned corrective action is
            consistent with the recommendation.
       2.   Management does not concur or partially concurs with the recommendation, but the OIG agrees that
            the proposed corrective action meets the intent of the recommendation.
       3.   For recommendations that include monetary benefits, management agrees to the full amount of OIG
            monetary benefits or provides an alternative amount and the OIG agrees with that amount.
 b
     Recommendations will be closed when the OIG confirms that corrective actions have been completed and are responsive.

October 2023       EVAL-24-02                                 II-8
                         Federal Deposit Insurance Corporation
                         Office of Inspector General

                                  3501 Fairfax Drive
                                  Room VS-E-9068
                                 Arlington, VA 22226

                                   (703) 562-2035

                                     

            The OIG’s mission is to prevent, deter, and detect waste, fraud,
            abuse, and misconduct in FDIC programs and operations; and to
             promote economy, efficiency, and effectiveness at the agency.

              To report allegations of waste, fraud, abuse, or misconduct
            regarding FDIC programs, employees, contractors, or contracts,
               please contact us via our Hotline or call 1-800-964-FDIC.

FDIC OIG website                X, formerly known as Twitter

www.fdicoig.gov                      @FDIC_OIG                       www.oversight.gov/